For the first time, a California nurse practitioner can run a practice with no physician attached to it. Gale is the practice OS for the NP who walks through — cash- and HSA-first, free software, an automatic back office, and a public page that is yours.
AB 890 wrote a ladder into the Business and Professions Code in 2020: first a transition to practice — three full-time-equivalent years or 4,600 hours, completed in California (§2837.103) — then at least three further years in good standing as a 103 NP (§2837.104). The board could not create the 103 certificate until early 2023, and said from the start that it would not be able to certify 104 NPs until 2026. That year has arrived: the application opened in BreEZe in early 2026, and the first NPs in California history to practice with no physician attached are filing now.
It is early enough that the board publishes no 104 count and no 104 processing-time estimate. Employers, credentialing committees, and carriers are still forming their reference points for what the certificate means. A patient searching for care meets the NP-owned practice as a new kind of thing — and the practices founded in this window get to define what it looks like.
The ladder also has a trap on its lowest rung: an NP who opens her own entity too early can stall her own clock, because the hours that count toward the 104 must be earned as a 103, in a setting the statute lists — and her own corporation is not one of them. The details, with citations, are in the guides below.
The numbers
Each figure below is dated and sourced, and carried with its full citation in the guides.
2026
The year the board said it could first certify 104 NPs — “the application to become a 104 NP will not be available until 2026.” It opened in BreEZe in early 2026.
The 103 certificate is created — the ladder’s first rung did not exist before this date.
BRN Sunset Review Report 2026, Table 7a footnote
2,722
103 certifications issued across FY 2022/23–2024/25 (843, then 1,030, then 849).
BRN Sunset Review Report 2026, Table 7a
≈45,838
Nurse practitioners the BRN oversees. On the order of six percent hold a 103 — a rough share drawn from two differently dated tables, not a precise rate.
Senate B&P background paper, March 2026 · BRN Sunset 2026
35 days
Average processing time for a complete 103 application in FY 2024/25 (78 days the year before).
BRN Sunset Review Report 2026, Table 7a
None
Published count of 104 certificates issued so far. The board’s processing-times table, updated 21 July 2026, carries no 104 row yet.
BRN Processing Times · BRN Sunset Review Report 2026
The watch
Pending in California
Statutes move, boards write rules, sunsets arrive. This watch is checked against primary sources on a standing cadence — last verified 11 August 2026 — and every item links the source it was read from.
Rulemaking in progress
California's Board of Registered Nursing is amending the regulations governing 103 and 104 NP certification.
Superbills for the patient who wants to claim out-of-network benefits.
The Fee Schedule — the one Gale document that states the fee.
Your practice page, in the public directory compiled from the NPPES registry.
Your credentials in one place — every license, DEA registration, board certification and plan enrollment you already hold, with reminders at 90, 60 and 30 days before one expires. Gale checks your NPI against the national registry and marks what it checked. It does not file applications; a credentialing service can.
Referrals from colleagues through your own link, acknowledged and booked in one place, and a view of which referral sources send you patients and which have gone quiet.
Practice notes on your public page, and your own notes on Gale’s health articles in the content library — credited to you, and nothing is public until you publish it.
An activity and access log that records who opened, changed or exported a patient’s chart, and when.
Connect Claude to set up your services, rates and hours by talking to it. It cannot open a patient record, move money or sign anything.
Tasks for you and your team, each with a due date, a priority and, if you choose, the patient it is about.
Supervision for the notes you co-sign: send a progress note back with a comment, or sign it yourself. Gale never signs for anyone.
A notifications inbox with the messages Gale sends you, each in full, and the unread ones marked.
Opening with the founding cohort
Concierge memberships — a monthly plan your practice sells on its own terms. Not sellable yet: enrollment fails closed behind a legal switch until counsel clears it. No countdown — when it clears, it clears.
The loop tracker — every referral, lab, and question a visible loop with an owner, a state, and a promised window. Closing one requires an outcome note; nothing silently expires.
The guided founding sequence — practice setup walked step by step with the first cohort: entity, posted prices, the practice page, the first visit.
Currents — the regulatory watch for your state and the latest evidence for your specialty, dated, sourced, and re-verified on a standing cadence. Quiet weeks say so.
Built, on sample data for now
Insurance billing — a billing console, coding you review and attest, and every claim followed from draft to paid. Today a claim is checked by Gale’s own test system: nothing reaches a payer and no money moves.
Outreach — check-ins for patients who have drifted, drafted overnight for you to approve. Approving sends nothing yet; patient contact stays off until it opens.
Your panel, sorted so the patients who are due or slipping out of care come first — a sort order, not a prediction — with show rates and between-visit activity counted beside it.
Practice health — whether notes get signed and Good Faith Estimates go out on time.
Guidance monitoring — the between-visit guidance a patient chooses to share with you, with anything off track listed first. It fills as patients share.
Workbooks — your charts, claims, referral pipeline, compliance records and clinician roster as tables you can edit. New accounts start on a sample practice.
A desktop bridge and scheduled agents, for work that runs while you are away. A scheduled agent can never send a message, move money or sign anything.
Analytics for the date range you pick — income, balances, claims, appointments and notes, and each report as a download. The money figures come from the same test system as billing.
Visit requests — the kind of visit a patient asks for, with a suggested length, checked off once the time is booked. For now a request is kept only in the browser it was sent from.
Currents
Best in class is a practice, not a plaque
Inside Gale, Currents also carries the guidance for your specialty — 47 entries across five specialties, plus a prescribing-and-safety band every prescriber sees, each dated, each linking its issuing body, re-checked on a standing cadence (last checked 11 August 2026).
The economics
Retiring the rent on the license
Short of full practice authority, a practice keeps a physician attached — standardized procedures here, a collaborating physician in other states — and the attachment has a price. The national matching services that publish rates listed monthly fees from $780 to $1,425 in a January 2025 compilation of vendor pricing, with initiation fees up to $500 at some. Our own guide declines to call any of that a benchmark: it is a private market, and a quoted figure is a market observation, not a going rate.
The 104 retires that line. What replaces it is not a smaller fee but a set of duties — a scope limit tied to your certification, four mandatory physician-consultation triggers, and a written referral plan (BPC §2837.104(c)) — spelled out here. The recurring cost goes to zero; the professional obligations remain, and they are yours.
Gale’s side of the ledger is deliberately short. The software is free, and Gale earns a fee on a card payment it takes or a flat fee on a claim your practice collects on its own — never as a subscription, never with per-feature line items, never a spread on your rate. The numbers themselves live in exactly one document, on purpose, so it can never quietly say two different things in two places: the Fee Schedule states it.
The guides
Eight pages written for exactly this decision — cited to the statute and to the board’s own filings. Every number above is carried in them, with its full citation.
Owning is legal; using the certificate inside it is not. A nursing corporation can be NP-owned, but it is not among the six settings BPC §2837.103(a)(2) lists, so the BRN is explicit that an NP working in a nursing corporation cannot practice there as a 103 NP without standardized procedures. And the hours that count toward the 104 must be earned after 103 designation, as a 103 — so opening your own practice too early can stall the clock that gets you to independence. Sequence first, then the door.
No. Both certificates authorize the same six functions in BPC §2837.103(c). The 104 removes the setting restriction — a solo office, your own corporation, a telehealth panel you own — not the scope ceiling. BPC §2837.104(c)(1) still confines practice to your education, training, knowledge, experience, and national certification.
It is a real boundary, not a formality. The BRN’s own summary is that a 104 NP may work independently within the population focus of their national certification — so a family-certified NP does not acquire a psychiatric panel on the strength of the certificate, and vice versa. Practice follows the certification you actually hold.
No. BPC §2837.104(b)(3) requires at least three years of practice in good standing, not inclusive of the transition to practice, and the BRN reads that through 16 CCR 1482.4 as three full-time-equivalent years or 4,600 hours of direct patient care after 103 designation. The two periods stack; they do not overlap.
No. The BRN states that moving to 103 or 104 status is optional and the traditional NP role continues unchanged — standardized procedures remain available either way, and no employer is required to demand the certificate. The 104 matters when you want a practice with your own name on the door.
A monthly plan your practice sells on its own terms — your contract with your patient, priced under the Internal Revenue Code’s HSA-compatibility rails, which the software enforces. It is not open today: no membership is offered or sold, and the selling switch fails closed until counsel clears it. When it opens, Gale services the billing as the practice’s agent — never a retained spread. The terms live in the Fee Schedule.
Cash- and HSA-first by design. You post your price; the patient pays the practice directly, HSA and FSA funds welcome; the software generates superbills a patient can submit to their own plan. Gale’s fee is charged to the practice, never to the patient, and only on transactions that actually pay — stated in the Fee Schedule.
Gale publishes a public directory compiled from the NPPES registry. Find your listing, claim it, and see how you rank for your own name — that page is the front door your independent practice will be found through.